The United States and Switzerland announced a new protocol to allow the Swiss government to provide information to the IRS on U.S. account holders of Swiss bank UBS.
Advertisement
Topics
International Tax
Global Tax Treatment of Equity Awards
Careful consideration is needed before a company begins to issue long-term incentives in foreign tax jurisdictions.
Congress Enacts Hiring Incentives Act with Tax Provisions
The Hiring Incentives to Restore Employment Act contains several tax items, the biggest of which is a payroll tax credit for employers who hire workers who have been unemployed for at least 60 days and who are not replacement hires.
IRS Provides Guidance on Deemed Dispositions by Canadian Emigrants
The IRS has issued guidance for individuals who emigrate from Canada and wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Rev. Proc. 2010-19).
The Software Regulations and Subpart F
The proper U.S. tax treatment of a sale or license of computer programs through a foreign subsidiary is challenging and potentially expensive in cash taxes. A practitioner must consider a variety of aspects and value exchanged in transactions and transfers when assessing transactions in software.
Profile of Multinational Businesses with Inbound Investments
Growth in international business brings increased opportunities for CPA firms to provide accounting and tax services. This article focuses on multinational businesses with inbound investments—i.e., foreign investors with business operations in the United States.
New Rules on Treatment of Certain Stock of a Foreign Corporation Under Sec. 7874
The IRS announced its intention to issue regulations that will identify certain stock of a foreign corporation that is to be disregarded for determining foreign corporation ownership under the requirements of Sec. 7874
Significant Recent Corporate Developments
This article discusses selected developments in U.S. federal income taxation of corporations and consolidated groups during 2009.
International Tax Compliance for Auditors and CFOs
In an environment where international tax examinations will play a larger role in tax audits, prudent financial executives and auditors will take the time to evaluate their current international tax compliance, assess any shortcomings, and correct them.
FBARs and Not-Yet-Reported Offshore Income: Penalties and Practitioners’ Issues
This item considers (1) options available for the client that did not disclose under the IRS’s voluntary disclosure program, which ended October 15, 2009; (2) practitioners’ responsibilities, including tax organizers and engagement letters; and (3) items suspended and/or extended to the June 2010 due date.
IRS Focuses on the FBAR
FBAR has graduated from a little-known filing requirement to a priority issue that should be at the top of every tax return preparer’s checklist.
U.S.-Source FDAP Income Compliance Designated as Tier 1 Issue
The IRS has designated the obligation of U.S. withholding agents to report and withhold on U.S.-source fixed or determinable annual or periodic (FDAP) income as a Large and Mid-Size Business (LMSB) Division Tier 1 issue.
Report on Foreign Bank and Financial Accounts: Compliance and Controversy
In recent months, concern over who is required to file the FBAR has escalated among taxpayers and tax practitioners alike. Along with stepped-up enforcement by Treasury and the IRS, this has made for a very interesting and challenging period in the life of the FBAR reporting requirement.
New Form 926: Return by a U.S. Transferor of Property to a Foreign Corporation
This article focuses on the history and purpose of Form 926 and describes changes that were made effective beginning in December 2008.
IRS Extends FBAR Filing Date for 2008 Filings
The IRS announced in Notice 2009-62 that it is extending for certain taxpayers the due date for filing calendar-year 2008 Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). Because Treasury is still working out various FBAR filing issues, it has decided to give certain taxpayers until June 30, 2010, to file FBARs for 2008 and earlier calendar years.
Preparing Canadian Structures for 2010
Effective January 1, 2010, Canada will look through tax-transparent U.S. LLCs and determine treaty eligibility at the member level.
Regs. Issued on 10/50 Foreign Corporations and Surrogate Corporations
The IRS has released final regulations on the application of separate foreign tax credit limitations to dividends received from noncontrolled Sec. 902 corporations (i.e., 10/50 corporations) (T.D. 9452).
U.S. Tax Effects of a Foreign Jurisdiction Audit
A tax audit in a foreign jurisdiction may affect the amount of foreign tax credit that a taxpayer claimed on a U.S. return for a prior year. To obtain the benefit of an increased foreign tax credit, the U.S. taxpayer’s claim for credit or refund must be timely.
Revised Form 1120-F: Practical Issues and Missed Opportunities
In early 2007, the IRS published a substantially revised Form 1120-F, U.S. Income Tax Return of a Foreign Corporation, to be used for tax years beginning in 2007.
Initial IRS Guidance Addressing EU Cap-and-Trade Systems, Subpart F Rules
In Letter Ruling 200825009, the IRS addressed for the first time the subpart F treatment of gains on sale of surplus carbon dioxide (CO2) emissions allowances.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
